Privacy Notice

GENERAL PRIVACY NOTICE MAY 2018

Purpose of this privacy statement

This is the privacy notice is for Verno Capital UK LLP. It is effective as of 25 May 2018. This privacy notice explains how the we collect and process your personal data. We are committed to protecting your personal data and this privacy statement will explain how we look after it and what rights you have.

Our Contact Details

Our contact details are:

Verno Capital UK LLP
Email address: gdpr@verno-capital.com
Postal address: 16 Old Queen Street, London SW1H 9HP
Telephone number: +44 20 3709 3040

If you have any questions about this privacy notice or how we deal with your personal data, including any requests to exercise your legal rights, please contact us using the details above.

Whose personal data do we process

We collect and process the personal data of various categories of people who interact with us, mostly investors and potential investors. This privacy statement applies to all personal data we obtain and process, whichever category you might fall into, and what data we use and how we use it will depend on the particular circumstances, as explained within this notice.

What sort of personal data do we process and how is it collected?

The types of personal data that we will collect and use will depend on various circumstances, for example, your relationship with us, why you are interacting with us and the type of services or products you want us to provide to you. The data may include, for example:

  • identity information, such as your name, the company you work for, your job title and department • contact details, such as your email address and phone number(s)
  • communication preferences
  • information which you provide in subscription documents and other forms
  • identity documents and other personal information used to carry out anti-money laundering (AML) checks, or to apply for travel documents on your behalf
  • any other personal data we may obtain through you interacting with us

Most of the time we obtain data from you directly as you interact with us, though sometimes we will conduct open source searches for information or receive qualified leads from a third party introducer.

For what purpose do we collect your personal data?

We will only use your personal data for the purposes for which it has been provided to us. Generally, we will process your personal data in order to provide you with those of our services and other offerings you want to receive from us. We will only use your personal data for the purposes for which it has been provided to us, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.

What lawful bases do we rely on to process your personal data?

We will only use your personal data in compliance with the law. Most commonly, where:
It is necessary for our legitimate interests (or those of a third party), and those interests do not override your interests or fundamental rights. Our legitimate interests typically involve direct marketing.
We need to comply with a legal or regulatory obligation. For example, we may be required to share your personal data with any legal or regulatory authority to which we are subject.

Who do we share your personal data with?

We may need to share your personal data with other organisations from time to time, but we will maintain responsibility for what they do with your data and how it is processed. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. For example:

  • Service providers who process data for us, including those providing IT and system administration services and hosting.
  • Other organisations such as auditors and compliance consultants
  • to competent authorities (including tax authorities), courts and bodies as required by law or requested or to affiliates for internal investigations and reporting

If we need to transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it as if it were being processed within the EEA. For example:

  • We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

How do we look after your data?

We have put in place appropriate security measures to help prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will we use your personal data for?

We will only keep your personal data for as long as necessary to fulfil the purposes for which we collected it or to enable us to comply with our legal obligations or enforce our legal rights.
At the end of the retention period, we will either delete your data completely, or anonymise it so that, for example, we can aggregate it with other data so that it can be used, without identifying you.

What are your legal rights?

You have the right to access information held about you and may request that we amend, delete or update such information. You may submit a request to: gdpr@verno-capital.com
Please note that there may be circumstances where we cannot delete information that we hold about you because of our legal obligations.

Accessing your data

Should you wish to access your data, the following information will apply:
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Changes to this privacy statement or to your data

This privacy statement may change from time to time so please check it periodically. Any significant changes will be posted on our website.
The personal data we hold about you needs to be accurate and up-to-date in order to comply with data protection law. Please let us know of any changes to your personal data so that we can correct our records.

Complaints

Please contact us at GDPR@verno-capital.com in the first instance if you have a concern about how we are dealing with your personal data, though you are entitled to complain at any time to the Information Commissioner’s Office (ICO) at www.ico.org.uk.

SPECIALIST EXPERTISE AND LOCAL,
ON-THE-GROUND KNOWLEDGE

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Legal Notices and Disclosures
IMPORTANT INFORMATION

Sales Restrictions and Investment Information
The information provided on this Website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject Verno Investment Management Limited or its affiliates (together “Verno”) to any registration requirement within such jurisdiction or country.The distribution of the information contained in this Website in certain countries may be restricted by law and persons who access it are required to inform themselves and to comply with any such restrictions. This information does not constitute an offer or solicitation in any jurisdiction. Prospective investors should inform themselves as to applicable legal requirements, exchange control regulations and taxes in the countries of their citizenship, residence or domicile.This Website is published solely for informational purposes and has no regard to the specific investment objectives, financial situation or particular needs of any person. Information contained herein is believed to be reliable but no warranty is given as to its accuracy or completeness and views and opinions, whilst given in good faith, are subject to change without notice. The information contained in this Website is not intended to constitute, and should not be construed as, investment advice. Potential investors in the fund that is described, or referred to, in this Website should seek their own independent financial advice. Verno neither provides investment advice to, nor receives and transmits orders from, investors in the fund described, or referred to, in this Website.An application for shares in the investment funds referred to on this Website should only be made having read fully the relevant offering documents.  It is your responsibility to read such offering documents and by making an application you will be deemed to represent that you have read such offering documents and agree to be bound by its contents.

You should note that, if you choose to invest in any fund described or referred to in this Website, your capital will be at risk and you may therefore lose some or all of any amount that you choose to invest.

Your Use of the Website

This legal notice sets out the terms on which you may make use of the Website, whether as a guest or a registered user, and apply to every page on the Website, whether or not such pages are individually disclaimed.  Please read these terms carefully before you start to use the Website.  By using the Website, you have indicated that you accept these terms and that you agree to abide by them.  If you do not agree to these terms, please refrain from using the Website.
You must NOTuse the Website (or permit or procure others to use it) as follows:

  • for any unlawful, improper or illegal purpose or activity;
  • to communicate or receive information that is obscene, indecent, pornographic, sadistic, cruel, or racist in content, of a sexually explicit or graphic nature, which promotes or incites discrimination, hatred or racism or which might be legally actionable for any reason;
  • in a manner intended to threaten, harass, or intimidate;
  • to violate Verno’s or any third party’s copyright, trademark, proprietary or other intellectual property rights;
  • to damage Verno’s name or reputation or that of our affiliated companies or any third parties;
  • to impersonate any of our employees or other person or use a false name while using our site or implying an association with us;
  • to penetrate our security measures or other entities’ systems (“hacking”);
  • to transmit unsolicited voluminous emails (for example, spamming) or to intercept, interfere with or redirect email intended for others using our site;
  • to generate excessive amounts of internet traffic, to interfere with our network or other’s use of our site or to engage in activities designed to or having the effect of degrading or denying service to users of our site or others;
  • to introduce viruses, worms, harmful code and/or Trojan horses onto the internet or into our site or any other entity’s systems and it is your responsibility to ensure that whatever you download or select for your use from our site is free from such items;
  • to post or transmit information that is defamatory, fraudulent or deceptive, including but not limited to scams such as “make-money-fast” schemes or “pyramid/chain” letters; and/or
  • to transmit confidential or proprietary information, except solely at your own risk.

When using the Website, you must comply with all applicable local, national and international laws and regulations, including those related to data privacy, international communications and exportation of technical or personal data. It may be illegal to download the information contained on our Website in certain countries and we and our affiliated companies disclaim all responsibility if you download any information from our Website in breach of any law or regulation of the country in which you reside.

User Identification Code
In respect of existing investors, you will be provided with a user identification code and password to access the Website.  You must treat this information as confidential and you must not disclose it to any third party or allow any third party to access the Website using your user code or password.  You agree to notify Verno immediately if you suspect unauthorised use of the Website or of your user identification code or password.

Distribution of information on this Website
It may be illegal to distribute the information on this Website to persons for whom it was not intended and Verno disclaims all responsibility in the event that there is an unauthorised distribution in breach of applicable laws or regulations.

Termination and Suspension of Access to Website
We reserve the right to deny you access to the Website, or immediately to suspend or terminate your access to the Website, or to disable any user identification code or password (whether chosen by you or allocated by us) at any time if your use of the Website (in our sole discretion) in any manner breaches these terms or for any other reason.

Privacy and Data Protection
As a result of your use of this website, Verno may hold and process personal information about you and may use it to send to you information about the fund managed by Verno. All personal data held by Verno will be treated in accordance with applicable data protection laws.

Intellectual Property Rights
The entire contents of this Website are subject to copyright with all rights reserved. You may download or print individual sections of the site for your personal use and information only provided that you retain all copyright and other proprietary notices. You may not reproduce (in whole or in part), transmit (by electronic means or otherwise), modify, link into or use for any public or commercial purpose the site without the prior written permission of Verno. You must not transmit any virus, “worm”, “Trojan horse”, or other item of a destructive nature to the site and it is your responsibility to ensure that whatever you download or select for your use from the site is free from such items.
Nothing on this Website should be construed as granting any licence or right in relation to any of our trademarks or those of our affiliated companies or any third party.

Linked Websites
Where a link to a non- Verno Website exists, to the extent permitted by applicable laws, Verno does not accept responsibility for the content of such site nor the products, services or other items offered through that site.

No Warranty
The Website, including information and materials contained in the Website, text, graphics, software, links and other items are provided “as is,” “as available”.  Verno does not warrant the accuracy, adequacy, completeness, timeliness or availability of the Website, and expressly disclaims liability for errors or omissions in the Website. There is no warranty of merchantability, no warranty of fitness for a particular purpose, no warranty of non-infringement, no warranty of any kind, implied, express or statutory, in conjunction with the website.

Limitation of Liability
In no event will Verno be liable for any damages, including, without limitation, direct or indirect, special, incidental, or consequential damages, losses or expenses arising in connection with the Website or use thereof or the inability by any party to use such Website, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure, even if Verno, or representatives thereof, are advised of the possibility of such damages, losses or expenses.

Indemnification
As a condition of your use of the Website, you agree to indemnify and hold Verno and its third party providers harmless from and against any and all claims, losses, liability, costs and expenses (including but not limited to attorneys’ fees) arising from your use of the Website, or from your violation of these terms.

Law and Variation
Your browsing in and use of this Website shall be deemed acceptance of, the laws of England and Wales. A condition of using this Website is that in the event of any dispute or proceeding you irrevocably submit to the exclusive jurisdiction of the English Courts and waive any objection to proceedings in such courts on the grounds of venue or on the grounds that the proceedings have been brought in an inconvenient forum.
Verno may revise this legal notice at any time by amending this page.  You are expected to check this page from time to time to take notice of any changes Verno makes, as they are binding on you.

Pillar III Disclosures
Verno Capital’s BIPRU 11.3 Disclosures as required by the FCA are available and may be requested from us. Please contact us at ir@verno-capital.com.

Each time you use this Website, a condition of use is that you comply with the above terms.